20180725Certificate of Attorney.pdf

RICEIVED
?0lB JUL 25 Pl{ 3: 28Yvonne R. Hogle (ISB# 8930)
Rocky Mountain Power
1407 W. North Temple, Suite 320
Salt Lake City, Utah 84116
Telephone No. [phone]
Facsimile No. [phone]
Emai I : [e-mail]
Attorneyfor RoclE Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IL
ot{
C
SSCOF.IM
TN THE MATTER OF THE INVESTIGATION
TNTO THE IMPACT OF FEDERAL TAX
CODE REVISIONS ON UTILITY COSTS
AND RATEMAKING
CASE NO. GNR.U- I8-O I
ATTORNEY' S CERTIFICATE
CLAIM OF CONFIDENTIALITY
RELATING TO DISCOVERY
RESPONSES
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I, Yvonne R. Hogle, represent Rocky Mountain Power in the above captioned matter. I am
Assistant General Counsel for Rocky Mountain Power.
I make this certification and claim of confidentiality regarding the response to the attached
Idaho Public Utilities Commission Staffdiscovery request pursuant to IDAPA 31.01.01 because
Rocky Mountain Power, through its response, is disclosing certain information that is Confidential
and/or constitutes Trade Secrets as defined by Idaho Code SectionT4-101, et seq. and 48-801 and
protected under IDAPA 31.01.01 .067 and 31.01.01.233. Specifically, Rocky Mountain Power
asserts that the attachments provided with the Company's responses to PIIC Data Requests 3, I't
Supplemental and PIIC Data Request 4, I't Supplemental contain Company proprietary
information that could be used to its commercial disadvantage.
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Rocky Mountain Power herein asserts that the aforementioned responses contain
confidential in that the information contains Company proprietary information.
I am of the opinion that this information is "Confidential," as defined by Idaho Code
Section 74-101, et seq. and 48-801, and should therefore be protected from public inspection,
examination and copying, and should be utilized only in accordance with the terms of the
Protective Agreement in this proceeding.
DATED this 25th day of July,20l8
Respectfully
R. Hogle
General Counsel
Mountain Power
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